Privacy Policy

Privacy Policy

Last Modified: June 22,2016

SVAAPTA IT-ALLY Solutions Ltd (“SVAAPTA UK”, “we”, “us” or “our”) respects your privacy and is committed to protecting personal data. This Privacy Notice explains how we collect, use, share and protect personal data when you visit our website, contact us, enquire about our services, interact with our business-development activities or otherwise deal with us in a business context. 

This notice does not normally apply to personal data that we process solely on behalf of a client while delivering contracted services. In those cases, the client will generally be the controller and SVAAPTA will act as processor under the relevant service agreement and Data Processing Agreement. 

1. Who we are 

1.1 SVAAPTA IT-ALLY Solutions Ltd is a company incorporated in England and Wales with company number 10169201 and registered office at 71–75 Shelton Street, Covent Garden, London WC2H 9JQ. For the processing described in this notice, SVAAPTA UK is generally the controller of your personal data. 

1.2 SVAAPTA UK is supported by group companies, including SVAAPTA IT-ALLY Solutions Pvt. Ltd. in India, which may provide delivery, operational, administrative or technical support subject to appropriate contractual and data-transfer safeguards. 

1.3 Privacy enquiries may be sent to legal@svaapta.co.uk. If we appoint a Data Protection Officer or another formal privacy representative, the relevant details will be published here. 

2. Personal data we may collect 

• Identity and business-contact data, such as name, job title, employer, business address, email address and telephone number. 

• Enquiry and relationship data, including the content of enquiries, meeting notes, proposals, opportunities, correspondence, preferences and records of our interactions. 

• Website and technical data, such as IP address, browser type, device information, pages viewed, referral information, log data and cookie or similar-technology identifiers. 

• Marketing and communications data, including communication preferences, event attendance, newsletter interactions and opt-out records. 

• Commercial and transaction data relating to prospective or existing client relationships, such as contract contacts, billing contacts, purchase orders and payment-related business information. 

• Information from public or professional sources, such as company websites, Companies House, LinkedIn, event attendee lists, referral partners or other lawful business sources. 

• Any other personal data you choose to provide to us in correspondence, forms, meetings or calls. 

2.2 We do not intentionally collect special-category personal data through the general website. Please do not send health, biometric, criminal-offence or other highly sensitive personal data unless it is genuinely necessary and we have agreed an appropriate channel and purpose. 

3. How we use personal data and our lawful bases 

3.2 Where we rely on legitimate interests, those interests may include responding to business enquiries, developing and managing professional relationships, marketing relevant B2B services, operating and securing our systems, preventing misuse and improving our services. We consider the impact on individuals and do not rely on legitimate interests where our interests are overridden by your rights and freedoms. 

4. Direct marketing 

4.1 We may send relevant business-to-business communications about SVAAPTA services, insights, events and opportunities where permitted by law. The rules may differ depending on whether the recipient is a corporate subscriber or an individual subscriber, and we apply PECR and UK GDPR requirements as applicable. 

4.2 Where consent is required, we will seek appropriate consent. Where the law permits another route, such as legitimate interests for certain B2B processing or an applicable soft opt-in, we may rely on that route subject to the required safeguards. 

4.3 You can opt out of marketing at any time by using the unsubscribe mechanism in the message or contacting us. We may retain limited suppression information so that we can respect your preference. 

5. Cookies and similar technologies 

5.1 Our website may use cookies, pixels, local storage, scripts and similar storage/access technologies. We provide further information in our Cookie Policy. 

5.2 We use consent controls for non-exempt technologies where required. Some technologies may be used without consent where a legal exception applies, for example where they are strictly necessary or another statutory exception is satisfied, subject to the conditions of that exception. 

6. Sharing personal data 

• SVAAPTA group companies where reasonably necessary for business operations, sales support, delivery planning, technical support or administration. 

• Service providers such as cloud hosting, CRM, email, communications, security, analytics, professional advisers and business-support providers. 

• Professional advisers, insurers, auditors, banks and finance providers where appropriate. 

• Authorities, courts, regulators or other parties where disclosure is required by law or reasonably necessary to establish, exercise or defend legal rights. 

• A buyer, investor or successor in connection with a genuine corporate transaction, subject to appropriate confidentiality and data-protection safeguards. 

6.2 We do not sell personal data as a standalone product. 

7. International transfers 

7.1 Because SVAAPTA operates internationally, personal data may be accessed from or transferred to countries outside the United Kingdom, including India, where our group delivery organisation is based. 

7.2 Where a restricted transfer requires a safeguard, we use an appropriate mechanism recognised under UK data protection law, such as an adequacy regulation, the UK International Data Transfer Agreement, the UK Addendum to approved standard contractual clauses, or another lawful mechanism. We also assess and apply supplementary measures where required. 

7.3 You may contact us for further information about the safeguards relevant to your personal data. 

8. Retention 

8.1 We retain personal data only for as long as reasonably necessary for the purpose for which it was collected, including to manage business relationships, comply with legal/accounting obligations, resolve disputes and maintain appropriate records. 

8.2 Our final retention schedule should be validated before publication. Current drafting assumptions for review are: general prospect/enquiry records approximately 24 months after the last meaningful interaction; client and contractual records generally for the relationship plus the period reasonably required for legal, tax and accounting purposes; marketing preferences until opt-out plus suppression records; technical/security logs for a period proportionate to security and operational needs. 

9. Security 

9.1 We use appropriate technical and organisational measures designed to protect personal data against accidental or unlawful loss, misuse, alteration, unauthorised disclosure or access. Measures are proportionate to the nature of the information, systems and risks involved. 

10. Your rights 

• request access to your personal data; 

• request correction of inaccurate or incomplete data; 

• request erasure where the law gives you that right; 

• request restriction of processing in applicable circumstances; 

• object to processing, particularly direct marketing and certain processing based on legitimate interests; 

• request data portability where applicable; 

• withdraw consent at any time where processing is based on consent; and 

• raise a complaint with the Information Commissioner’s Office (ICO). 

10.2 Not every right applies in every circumstance. We may need to verify your identity before responding to a rights request. 

10.3 You have an absolute right to object to direct marketing. If you object, we will stop using your personal data for that marketing purpose. 

11. Automated decision-making 

11.1 We do not currently intend to make solely automated decisions about website visitors or business contacts that produce legal effects or similarly significant effects. If this changes, we will update this notice and provide the information required by law. 

12. Third-party links 

12.1 Our website may link to third-party websites or services. Their privacy practices are controlled by those third parties, and we encourage you to review their notices before providing personal data. 

13. Complaints and contact 

13.1 Please contact us first at legal@svaapta.co.uk if you have a question, request or concern about our use of personal data. 

13.2 You also have the right to complain to the Information Commissioner’s Office. The ICO’s current contact and complaint information is available at ico.org.uk. 

14. Changes to this notice 

14.1 We may update this notice to reflect changes in our services, technology, legal requirements or data practices. The current version and effective date will be published on our website.